PRIVACY POLICY – PAYTWEEN

 

This Privacy Policy shall form part of the Paytween Terms and Conditions.

 

About us

 

PAYTWEEN, LLC, with registered office at 1405 Langley Place, McLean, VA 22101, USA (henceforth, “Paytween”) is responsible for the Paytween Application (henceforth, “the App”) and informs the User and/or Client of the existence of a personal data file owned by Paytween for which it is responsible.

 

The objective of our Privacy Policy

 

The objective of this Privacy Policy is to inform the User of the App and Paytween Clients about:

 

(1) the data we collect;

(2) the reasons for collecting those data;

(3) the consequences of not providing the data, should the user choose to do so;

(4) how we use these data;

(5) the rights of App Users and Paytween Clients.

 

This information is important for Paytween and, especially, to its Users and Clients. For this reason, we recommend that you read it carefully.

 

It is important that App Users and Paytween Clients understand that simply by downloading the App and completing the registration process or just visiting Paytween’s website and filling in the Personal Data fields, the User and/or Client is freely, unconditionally and unequivocally agreeing to the collection and processing of their data by Paytween under the terms of our Privacy Policy without prejudice to User and Client rights according to the same and applicable laws.

 

The Personal Data we collect

 

We collect Personal Data from Users who are over thirteen (13) years of age because we believe in the importance of preserving the safety and privacy of minors. As such, minors younger than thirteen (13) years of age cannot register with the App. If we find out that a minor under thirteen (13) has registered as a User, we will eliminate his or her information as quickly as possible.

 

More specifically, Paytween collects the following data from each User and/or Client (hereinafter, “Personal Data”):

 

(1) First and last names, a cell phone number, and an e-mail address in order to complete App registration;

(2) The type of device the App is being used with and the web browser model once the App has been downloaded and registration complete;

(3) Profile photo to be used in the App;

(4) Photographs, contents, voice, etc. should the User share them in the chat function of the App. If the User shares photos from the gallery on their mobile device or from their cloud with access from said device, we will request access to said files in order to process the messages which contain them and send them to the recipients;

(5) Telephone numbers in the User’s Contacts.

 

We will maintain your Personal Data for the time it takes to provide the service and fulfill the terms stated in the present Privacy Policy, unless the law requires or allows us to maintain them for a longer period of time.

 

It is important that the User clearly understands that he or she may provide or share all or some of his or her Personal Data with third parties using the functions offered in the App, such as chat, and in such cases, the User is fully responsible for the consequences of said actions given that it is the User that is communicating with third parties who may copy, resend, create other files, etc., actions over which Paytween declines any responsibility.

 

We may also collect aggregated data, which is to say, data which cannot be linked to one specific person (hereinafter, “Non-Personal Data”). Paytween may collect, process, transfer, and disclose the following Non-Personal Data for any purpose.

 

Some types of Non-Personal Data, and the purposes for which it will be used, include: language, post code, area in which the App is being used, time zone, etc. In an attempt to get to know what our Users and Clients do with the App, the type of activities they take part in, the amounts they spend, where and how they spend, etc. This is in order to improve our product and offer, where appropriate, additional services and advertising.

 

The App, the website, and any other Paytween product contain or may contain links to websites, applications, products, and services by other companies, particularly applications and websites for the making of payments. It is important to point out that the collection of data by third parties, particularly sensitive data such as payment information, credit card information, passwords for other payment methods, PIN numbers, etc. is not the responsibility of Paytween, the safekeeping of this Personal Data to be the responsibility of said applications and payment methods. Therefore, Paytween shall not be held responsible in any claim against it resulting from the decision of the User to communicate said data, it being responsibility of the User and/or the application, website, or service provided by other companies who collect, store and/or process the data and UNDER NO CIRCUMSTANCES WILL PAYTWEEN BE HELD LIABLE for any claim regarding the processing of data carried out by third parties, such processing it being solely governed by those other companies respective privacy policies. We strongly recommend that Users consult the privacy policies of said third parties.

 

We will at all times use information collected about you in accordance with the Data Protection Act 1998.

 

What’s Paytween’s purpose in collecting Personal Data

 

The reasons why we collect and process our Clients and Users’ data in Paytween include:

 

(i) Fulfilling our obligation to comply with the agreement or contract existing between Paytween and our Users and Clients, specifically, the information necessary to complete App registration and allow the App to offer Users and Clients the functions that are the reason the App exists as well as the exchange of messages, with or without content, calculations, information about debts or credits amassed by the other members of the group, etc.;

(ii) Analysis of data with regard to App use and for statistical purposes, improved functioning, the offering of additional services which improve the App, the development of new products and management information;

(iii) Marketing: processing Personal Data for promotional activities;

(iv) Compliance with legal obligations;

(v) Security and Integrity: in the case of the suspicion of fraud and/or abuse of the Paytween App, we can block Users from the App or from access to the App.

(vi) Information: User data allows us to provide information on Paytween products, App updates, events, etc.

(vii) Verification: Paytween may use Personal Data including, for example, date of birth to verify a User’s identity to determine if they are old enough to use the App.

(viii) Important Notifications: occasionally, we will use the data to send Users notifications regarding acquisitions, changes in the functioning of the App or to our General Terms and Conditions, Privacy, Intellectual Property, or Cookies Policies, or any other legal regulation or information regarding the relationship between Paytween and its Users;

(ix) If Users participate in a give-away, a contest, or a promotion, we may use the data provided to administer these programs.

 

What happens if I decide not to consent to the collection and processing of Personal Data

 

In order to provide the service we offer, Users must provide the necessary information. Otherwise, the application cannot function and thus, the User will neither be able to download it nor to use it.

 

To whom do we transfer Personal Data

 

Users authorize Paytween to transfer or communicate Personal Data for all or some of the following reasons:

 

– Compliance with legal obligations: regulatory bodies, agencies, etc.

– Personal Data may be transferred to other business units, subsidiaries, and/or affiliates of Paytween both within and outside the United States and within and outside the European Economic Area for purposes foreseen in this Privacy Policy. Paytween business units, subsidiaries and/or affiliates can be found on the following webpage: www.paytween.com

– For statistical purposes, using aggregate data, for ratings, audience, dissemination, and use; for economic viability and financing, etc.

– User data may also be processed and used to send Users information and provide services within the App as well as for the communication with users and the execution of promotional activities jointly with third parties to whom Paytween may communicate information and aggregate, non-identifiable Personal Data, commercial offers and advertising of its products by any means, whether physically or digitally, expressly including e-mail.

– Paytween may share Personal Data and Non-Personal Data with other companies dedicated to any of the following activities, inter alia: data processing on behalf of Paytween, offering its products, meeting the orders of clients, customer services, analysis of customer’s interest in our products and services, surveys and promotions. These companies are required to protect the data and may be located in any country.

– Similarly, in certain cases it is possible that Paytween may have the legal obligation to disclose Personal Data, being served with a warrant, in the context of judicial proceedings, or at the request of a public or government authority, both within and outside the User’s country of residence.

– In the case of restructuring, merger, or sale, we will transfer all Personal Data collected to the corresponding third party.

– Processing of User Personal Data so that Paytween may send commercial information on its products and services as well as any other websites and Applications operated by Paytween in digital marketing, financial services, and any other sectors in this Privacy Policy. 

 

The aforementioned sending of commercial information includes: product presentation, offers for products and services, discounts, packages, promotions, etc. Similarly, the User consents to and authorizes Paytween to process his or her data for the purposes of statistics (segment information by types of products acquired, areas in which the most transactions occur, volume of business by area, etc., inter alia), commerce, and to use any other available marketing tools.

 

When can Users/Clients access their data

 

Users may access their data at any time to consult or update it. They may also consult the registry of their activity kept by Paytween in order to decide which type of User data they want to allow to be stored in their account when using Paytween’s services.

 

The use of cookies

 

We use cookies in Paytween to identify the User’s browser and device, to collect and store information when the User interacts with the services offered in the App and on the website. For further details about the cookies we use and their purposes, please visit our Cookie Policy.

 

Paytween User and Client rights

 

Users of the App and Clients of Paytween with doubts regarding the Privacy Policy or how their Personal Data is processed in accordance with said Policy, or who wish to know what Personal Data of theirs Paytween has, correct it if it is erroneous, or want to inform us of a problem or complaint, may contact us at the address listed below.

 

Paytween may update or modify its Privacy Policy. It will likely do so periodically, whether to accommodate the changing legal requirements or to adapt the Policy to the type of processing we want to carry out. In any case, we will always communicate any substantial changes in the Privacy Policy with an ad in the App itself which will redirect the User to a website in which he or she can consult the text of the new Privacy Policy, copy it, download it, etc.

 

Likewise, if any User wishes to have his or her Personal Data eliminated, he or she can contact us. However, we reserve the right to not process those requests which are inappropriate or burdensome, which endanger the privacy of third parties, which are not feasible, or which local laws do not require access to.

 

Requests for access, correction, or elimination of data may be sent to the e-mail address dedicated to privacy issues contact@paytween.com or to the following postal address:

 

PAYTWEEN, LLC

1405 Langley Place

McLean, VA 22101

USA

 

Browsing of the website implies the full and unconditional acceptance by the User of this Privacy Policy and of the collection and processing of his or her Personal Data under the terms described herein, barring express refusal to the contrary by the User.